Data Lead for Job Applicants/Prospective Employees: Julia Mixter, Head of HR
As part of any recruitment process, the Royal Automobile Club (the Club) collects and processes personal data relating to job applicants. The Club is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
What information does the Club collect?
The Club collects a range of information about you. This includes:
- your name, address and contact details, including email address and telephone number;
- details of your qualifications, skills, experience and employment history;
- information about your current level of remuneration, including benefit entitlements;
- whether or not you have a disability for which the Club needs to make reasonable adjustments during the recruitment process;
- information about your entitlement to work in the UK; and
- equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.
The Club collects this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.
The Club will also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks and the Disclosure and Barring Service (DBS). The Club will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.
Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).
Why does the Club process personal data?
The Club needs to process data to take steps at your request prior to entering into a contract with you. It also needs to process your data to enter into a contract with you.
In some cases, the Club needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.
The Club has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the Club to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. The Club may also need to process data from job applicants to respond to and defend against legal claims.
Where the Club relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.
The Club processes health information if it needs to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.
Where the Club processes other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.
For some roles, the Club is obliged to seek information about criminal convictions and offences. Where the Club seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.
The Club will not use your data for any purpose other than the recruitment exercise for which you have applied.
If your application is unsuccessful, the Club will keep your personal data on file for a period of three months in case there are future employment opportunities for which you may be suited.
Who has access to data?
Your information will be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.
The Club share your data with third parties, that the Club works with during the recruitment process. Your data will be shared for the specific purpose of processing your application of employment and our third party providers have a signed agreement with the Club on that basis. The Club will also share your data with former employers to obtain references for you, if an offer of employment is made, together with employment background check providers to obtain necessary background checks and the Disclosure and Barring Service to obtain necessary criminal records checks.
The Club will not transfer your data outside the European Economic Area.
How does the Club protect data?
The Club takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties. Relevant policies include the Data Protection Policy available on the Club’s Career webpage.
For how long does the Club keep data?
If your application for employment is unsuccessful, the Club will hold your data on file for three months after the end of the relevant recruitment process.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held are contained in the Employee Privacy Notice.
As a data subject, you have a number of rights. You can:
- Correct any data we hold about you that is not correct (Rectification)
- Have any data not covered by our retention policy deleted (Erasure)
- Block or suppress the further processing of your personal data in certain circumstances (Restriction)
- Request access to personal data that we hold about you (Subject Access)
- In some circumstances, receive the personal data which you have provided to us, in a structured, commonly used and machine-readable format and have this transmitted to another data controller (Data Portability)
- Withdraw consent where this is the legal basis for us processing your information
- Object to processing where the Club is relying on its legitimate interests as the legal ground for processing
- require the Club to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- ask the Club to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation’s legitimate grounds for processing data.
If you would like to exercise any of these rights, please email firstname.lastname@example.org
If you believe that the Club has not complied with your data protection rights, you can complain to the Information Commissioner.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the Club during the recruitment process. However, if you do not provide the information, the Club may not be able to process your application properly or at all.
Recruitment processes are not based solely on automated decision-making.
Reference should be made to the following;
- Data Protection Policy